A federal judge in Los Angeles has put a stop to immigration agents making warrantless arrests in Southern California without first assessing if the targeted individuals are likely to flee. U.S. District Judge Maame Frimpong issued a preliminary injunction on Wednesday, finding that federal immigration agents have been “regularly abstaining from conducting a likelihood of escape analysis at all.”
The court’s decision highlighted that this practice is an ongoing policy, not just isolated incidents of agents acting alone. Testimony from the U.S. Department of Homeland Security’s own agents supported the conclusion that the issue stemmed from this illegal warrantless arrest policy.
The judge also certified a class of individuals who, since June 6, 2025, have been or will be arrested by federal agents for alleged immigration violations without a warrant and without an individualized escape risk assessment. Under federal law, immigration agents are permitted to make a warrantless civil immigration arrest only if they have probable cause to believe both that a person is undocumented and that the person is likely to escape before a warrant can be obtained.
In addition to stopping the practice of conducting warrantless arrests without first determining escape risk, the court has mandated several new conditions for the federal government. Immigration agents must now consider the totality of circumstances known to them before making an arrest, including the risk of escape. Agents must also cease relying on a January memorandum from former acting U.S. Immigration and Customs Enforcement director Todd Lyons, which illegally suggested that merely being undocumented was sufficient to establish a likelihood of escape. Furthermore, agents are now required to document their analysis of escape risk when performing warrantless arrests within the Central District of California.
Mayra Joachin, senior staff attorney at the ACLU Foundation of Southern California, released a statement calling the ruling “one of the most important decisions to date in the community’s effort to end the federal government’s cruel and illegal practice of abducting people and separating them from their families.” Joachin added that by requiring agents to follow the law, the order “should put an end to hundreds — if not more — of unlawful arrests that continue throughout Southern California.” The ACLU stated they would closely monitor compliance.
The U.S. Department of Homeland Security (DHS) had previously commented on the preliminary injunction, insisting that federal agents prioritize protecting American citizens. According to a statement from DHS, “Our agents are focused on protecting the American people — not entertaining performative outrage.” The department also asked where the media’s outrage was for “Angel families,” referring to family members of those killed by undocumented individuals.
The judge’s order stems from the closely watched Vasquez Perdomo vs. Noem case, a lawsuit challenging the legality of immigration raids conducted in Southern California. Since these raids began last year, the ACLU alleges that federal agents routinely carried out warrantless arrests without conducting the required escape risk evaluation. A review of 113 arrest records, cited by the plaintiffs, found that nearly 80% either contained no assessment of escape risk or relied on largely standardized language, indicating a lack of individualized determination.
This decision is distinct from a related challenge alleging racial profiling and stops made without adequate suspicion of a crime. That challenge, which contends that DHS immigration raids in the region are not only unlawful but also deliberately designed to target Latino communities, will be heard by Judge Frimpong at a later date. The judge had previously rejected the Trump administration’s attempt to end this particular lawsuit.
According to the ACLU, stops across the Central District of California have continued even after street raids ceased last summer. Residents, workers, and advocacy groups had sued DHS in July 2025, alleging unconstitutional stop and detention practices by agents tied to arbitrary enforcement quotas. While a temporary restraining order initially limited certain enforcement actions, the Supreme Court granted the government’s request to stay that order in August 2025, allowing the challenged practices to continue. Plaintiffs’ attorneys recently filed documents in Los Angeles federal court that allegedly show text messages and body-cam footage revealing agents using racial slurs to identify arrest targets. Immigration advocacy groups argued, according to a court filing, that this evidence showed DHS agents primarily targeted “people who appear Latino and low-income or working-class.”
